Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
Insurance brokers renew PI cover into a market that is more sensitive to their own compliance record than any other profession's. Insurers writing broker E&O look closely at FCA authorisation history, at appointed-representative structures, at network arrangements, at the DISP complaints record and at the E&O history itself. Renewal is when the broker's own regulatory posture is placed on the table for another broker to look at. Under MIPRU 3 the FCA sets minimum PI cover for regulated intermediaries; adequacy above the minimum is a judgement for the firm and its board.
Eight to twelve weeks before renewal is the working range. Firms with a network or appointed-representative structure, meaningful E&O history, or a live FCA supervisory matter should be at the twelve-week end. Smaller directly-authorised firms with a clean record can work to eight weeks. The reason for the earlier start is that the E&O market for brokers has narrowed — the number of insurers writing broker risk with real appetite is small, and each of them manages capacity by permission profile and by claims record. Placing the account with an insurer whose appetite matches the firm's activity mix rewards early engagement.
Under section 3 of the Insurance Act 2015 the firm owes a duty of fair presentation. The proposal will ask for a commission and fee split by client type and product line — commercial, personal, high-net-worth, motor, property, professional indemnity, cyber, marine, credit — because each carries a different E&O profile. FCA permissions should be listed exactly as held. Appointed-representative structures need to be described, including the number of ARs, their activities and the firm's oversight framework. The DISP complaints record over at least five years goes in, together with any FOS decisions. E&O claims and notifications go back further — typically ten years. Any Section 166 skilled-person review, thematic review correspondence with the FCA, or MIPRU capital position issue is disclosed. Under MIPRU 3.2 the minimum PI cover is currently set by reference to income and by policy limit and aggregate provisions; the firm should evidence its compliance calculation.
Appointed-representative arrangements have been a focus of FCA supervisory attention since the Vesting Order changes, and insurers writing broker E&O scrutinise the AR oversight framework closely. Network membership does not remove the principal's E&O exposure for AR activities and can add exposure for the network's own conduct. Personal-lines aggregation is real — a systematic error in a comparison-site journey or in a product recommendation flow can aggregate across a book. Insurer-selection risk sits with the broker: placing cover with an unrated or overseas insurer that subsequently fails to pay a claim generates an E&O claim against the broker itself. Wordings that carve out commission-and-fee disputes, that limit fraudulent-insurer exposure, or that narrow the definition of professional services are wording points to test carefully. Run-off cover after cessation of trading needs a plan under FCA sourcebook requirements. Cyber overlap for brokers is significant — a data breach exposing client information generates both PI and cyber exposure and both wordings need to be mapped.
95% of Apex clients renew with Apex. The number describes the pattern of firms coming back when the broker has done the work. For an insurance broker being broked by another broker, that pattern matters more than usual — the firm on the receiving end knows exactly what a well-handled renewal looks like and what a phone call to the incumbent looks like. Firms whose renewal was worked properly, whose FCA and DISP position was presented honestly, whose wording was compared plainly, tend to come back. Firms whose broker rolled forward the incumbent tend not to.
The MIPRU 3 minimum sets a floor, and a floor is not a limit strategy. A broker whose commission and fee income has grown materially since the last renewal will find the MIPRU 3 minimum has moved with it, and adequacy above the minimum is a board-level judgement that deserves annual scrutiny rather than roll-forward. The right limit review considers the largest single client relationship the firm holds, the aggregate exposure across a book where a systematic advice or placement error could aggregate, the AR arrangements and the oversight framework's ability to prevent AR-level errors reaching principal-level exposure, and the run-off implications under FCA sourcebook requirements. Cyber exposure sits alongside — the PI wording and any cyber wording need to be mapped together so a data-incident claim does not fall between the two.
One named broker owns the account. The submission is drafted with the firm, distinguishing commission and fee income by product line and client type in the categories broker E&O underwriters use to price the risk. FCA permissions, AR structures and the DISP position are presented directly rather than left to be pieced together. Every insurer with genuine broker-E&O appetite on our panel is approached where it makes sense. Wording differences — AR carve-outs, fraudulent-insurer clauses, commission-and-fee disputes, network-membership treatment, defence-costs treatment, retroactive dates — are set out in plain English. Where the firm holds a separate cyber policy the interaction with PI is mapped. A s